State Department of Revenue v. Adolph Coors Co.

The majority holds that the purchases of beer keg materials by Adolph Coors Company (Coors) for use in its beer-making business qualified for the container exemptions under sections 39-26-102(20)(a) and 39-26-203(l)(f)(I), 16B C.R.S. (1982), and were thus exempt from the Colorado sales and use taxes. In reaching this result the majority refuses to read a resale requirement into the exemption statutes, and then reasons that even under a resale requirement the beer keg materials were indeed purchased for resale and resold to Coors’ distributors. I dissent from the court’s opinion on both counts.